PLAINTIFF'S MOTION FOR LEAVE TO FILE THE FOLLOWING UNDER SEAL

1. PLAINTIFFS' MOTION FOR LEAVE TO AMEND COMPLAINT AND REOPEN DISCOVERY AND EXHIBITS THERETO; AND

2. AMENDED COMPLAINT AND EXHIBITS THERETO UNDER SEAL

MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; [PROPOSED] ORDER

GEORGE FOLEY, Jr., Magistrate Judge.

Plaintiff Samick Musical Instruments Co., Ltd. ("Plaintiff" or "Samick") hereby moves this Court for an order sealing Plaintiffs' Motion For Leave To Amend Complaint And Reopen Discovery and the Exhibits thereto ("Motion"), and the Amended Complaint along with its Exhibits. These documents are filed concurrently with this Motion.

In January 2010, Plaintiff Samick and QRS Music Technologies, Inc. ("Defendant QRS") entered into an Agreement. See September 15, 2016 declaration of Boyoon Choi, ¶ 2. This Agreement forms the basis for the majority of the claims being presently asserted by Plaintiff Samick against Defendant QRS. Id. The 2010 Agreement contains a strict confidentiality provision prohibiting disclosure of the terms of the 2010 Agreement and its accompanying Exhibits to any third party. Id., ¶ 3. The parties have also agreed to keep confidential and under seal the deposition testimony regarding the parties' financial information. Id.

Seeking to honor this Agreement and not breach the terms of the confidentiality provision, Plaintiff seeks permission to file under seal the full version of the Amended Complaint, the 2010 Agreement and its Attachments, as well as the Motion Id. ¶ 4. A redacted version of the Amended Complaint with non-confidential Exhibits A and B has been filed concurrently herewith. Id. As stated above, the Amended Complaint has been redacted because many of the facts and causes of action refer directly to the terms of the 2010 Agreement. Id. Likewise, Plaintiff seeks to have the Motion and its Exhibits filed under seal to honor the Agreement, and protect the confidential financial information of the parties. Id., ¶ 5.

LR 10-5(b) provides in part "...papers filed with the Court under seal shall be accompanied by a motion for leave to file those documents under seal, and shall be filed in accordance with the Court's electronic filing procedures."

Previously, this Court granted Plaintiff's motion to file the Original Complaint under seal. Doc. # 12.

In good faith, seeking to honor and not breach the terms of the parties' 2010 Agreement, Plaintiff Samick requests that this Court grant its Motion to file Plaintiffs' Motion For Leave To Amend Complaint And Reopen Discovery and Exhibits thereto, as well as the Amended Complaint along with Exhibits under seal.

IT IS ORDERED.

DECLARATION OF BOYOON CHOI

I, Boyoon Choi, do hereby declare and state as follows:

I declare under penalty of perjury pursuant to the laws of the State of Nevada that the foregoing is true and correct to the best of my knowledge.